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Welcome to the Vermont Model Criminal Jury Instructions. The instructions are sponsored by the Vermont Bar Association.
Use the drop-down menus above or the search function below to find individual instructions and the accompanying reporter's notes.
In addition, clicking on the menu headers above will show a table of contents for that section, and there is also a master table of contents available. Long-time users of the instructions will find the master table of contents to be in the familiar format.
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You may search for an instruction by using the name of the crime (e.g., kidnapping) or by using the statutory citation (e.g., 13 V.S.A. 2405 or, more simply, 2405). Note that the search software is simply reading the text on each page, and thus doesn't recognize "VSA" without the periods.
Category Archives: Uncategorized
Voluntariness of Confession; Invited Error Doctrine
October 8, 2020: The Committee has added a reference to State v. Kolts, 2018 VT 131, ¶¶ 39–41 to the reporter’s note for CR05-351 (Defendant’s Out-of-Court Statements), and a reference to State v. Morse, 2019 VT 58, ¶¶ 6–7 (discussing … Continue reading
Disclosure of Sexually Explicit Images Without Consent
October 2, 2020: The Committee has revised the instruction and reporter’s note for the crime of “Disclosure of Sexually Explicit Images Without Consent” (CR27-611) to reflect the Vermont Supreme Court’s decision in State v. Van Buren, 2018 VT 95, ¶¶ … Continue reading
Multiple Defendants
September 18, 2020: The Committee has added a new instruction (CR04-051) and reporter’s note for use in cases with more than one defendant on trial.
Reckless Endangerment
September 18, 2020: The Committee has revised the instructions and reporter’s note for Reckless Endangerment (CR22-121, -126) to be consistent with the recent revision to the general definition of recklessness (CR06-141).
Eluding a Police Officer
September 8, 2020: The Committee has updated the instructions and reporter’s note for the crime of eluding a police officer.
Recklessness
August 28, 2020: The Committee has revised the instruction for the mental state “recklessly,” CR06-141, and the accompanying reporter’s note. The revised instruction and note can be found on the Mental Elements page.
Aggravated Animal Cruelty
December 20, 2019: The Committee has prepared instructions and a reporter’s note for aggravated animal cruelty, available here.
Juror Unanimity
November 22, 2019: The Committee has revised the reporter’s notes for the general and specific unanimity instructions to incorporate a reference to the recent case of State v. Robitille, 2019 VT 36, ¶¶ 47–50. The Committee has also inserted a … Continue reading
Partial Rule 29 Dismissal
October 22, 2019: The Committee has added a new instruction for situations where one or more charges have been dismissed pursuant to a V.R.Cr.P. 29(a) motion for judgment of acquittal, but where other charges remain for the jury’s consideration. The … Continue reading
DUI: Serious Bodily Injury and Death Resulting
September 20, 2019: The Committee has added new instructions for DUI-serious bodily injury and DUI-death resulting, and a new reporter’s note to accompany those instructions. Those revisions are available here.